Noam Mohr, representing People for the Ethical Treatment of Animals PETA commented on a document of the US Agency for Animal and Plants Health Inspection APHIS, department of Agriculture, concerning the regulations to establish a voluntary program for the control of low pathogenic avian influenza in commercial poultry.
PETA has a strong opinion about the animal welfare during killing of farm animals. Read their reaction:
“On behalf of People for the Ethical Treatment of Animals (PETA) and our more than 1 million members and supporters, I am writing with regard to Docket No. APHIS 2005 0109. In particular, I ask that the USDA, as part of its government control program for low pathogenic avian influenza (LPAI), include provisions to require or, at a minimum, encourage the use of depopulation methods that provide the least traumatic death possible for birds who are slated to be killed.
The USDA has made efforts to include animal welfare issues in its high pathogenic avian influenza (HPAI) response plan, including permitting only methods approved by the American Veterinary Medical Association and holding discussions with scientists and animal protection organizations, including PETA, to consider the suffering inflicted by various killing strategies.
It is therefore surprising that these same issues are completely absent from the LPAI program. Unlike HPAI, which has not struck the United States in years, LPAI outbreaks are regularly detected. For example, Pennsylvania alone detects 15 to 20 outbreaks per year. Each outbreak typically requires the mass killing of entire flocks of birds, each of which can number in the tens of thousands.
The sheer magnitude of the number of animals involved makes it ethically incumbent upon us to minimize their suffering. While the interim rule makes many references to the international standards set by the World Organization for Animal Health (OIE), it fails to mention that OIE guidelines require that when animals are killed for disease control purposes, methods used should result in immediate death or immediate loss of consciousness lasting until death; when loss of consciousness is not immediate, induction of unconsciousness should be non-aversive and should not cause anxiety, pain, distress or suffering in the animals.
Particularly in light of reports from abroad of burning and burying live animals, methods that shock the conscience and violate the most basic standards of animal welfare, the USDA should take all necessary steps to prevent similar abuses from occurring in the United States.
Recommendations
INERT GASES: In particular, when large numbers of birds are to be killed, we recommend the use of inert gases, such as nitrogen or argon, or inert gas mixed with 30 percent carbon dioxide. Inert gases are completely undetectable to birds and provide the most painless death possible under these circumstances. Particularly in cases where sheds cannot be sealed properly (as is often the case, such as, for example, with laying hens), mobile gassing carts filled with inert gas, which render birds painlessly unconscious before killing them via anoxia, should be considered the method of choice. Birds should be carried to the carts individually and upright in order to avoid causing injury, which could lead to disease transmission from exposure to blood or other bodily fluids.
CARBON DIOXIDE: In the United States, the most common method of mass killing of poultry for disease control is the use of carbon dioxide. Carbon dioxide is extremely aversive at high concentrations and is described by humans as ?piercing, stabbing, painful, or causing the eyes to burn or water.? (Conlee KM and others. 2005. Carbon dioxide for euthanasia: concerns regarding pain and distress, with special reference to mice and rats. Laboratory Animals 39: 137?61.) If introduced to the birds at extremely low temperatures, as is common, it can result in death by freezing. Often birds are first rounded up and wrapped in plastic tarp, causing not only extreme fear, but also trampling. Please make every effort to ensure that (1) if carbon dioxide is used, it is pumped directly into sheds without the use of plastic sheeting, a proven method used successfully in the 2004 outbreak of the HPAI in British Columbia; (2) where possible, lower, less aversive levels of carbon dioxide are used to render animals unconscious before they are killed with high concentrations; and (3) measures are taken to prevent birds from freezing to death.
OTHER METHODS: Less humane methods of mass killing of birds should not be considered acceptable, such as cervical dislocation, starvation, bludgeoning, bleeding, maceration (except in the case of newborn chicks), and suffocation, including such common methods of suffocation as burying animals alive, shutting off ventilation in sheds, and smothering birds with firefighting foam. Please do everything in your power to discourage these methods. Avian flu response plans will have an enormous impact on the suffering of many millions of animals. Along with protecting the public, the implementation of methods that minimize the pain and suffering of animals should be an overriding priority and be incorporated into this interim rule. Feel free to contact me with any questions. Thank you very much for your consideration.
Sincerely,
Noam Mohr Farmed Animal Researcher People for the Ethical Treatment of Animal.”
Read the APHIS Report: APHIS report 2005, Sept. ’06
